How Do We Calculate SAP If We Converted To Pass/Fail Grades Due To Coronavirus?

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This guidance is not award-year-specific and applies across award years.

This AskRegs Knowledgebase Q&A was updated to include clarification NASFAA received from the U.S. Department of Education (ED) following publication of the guidance about the COVID-19 waiver and flexibility end dates in the June 14, 2023 Electronic Announcement (GENERAL-23-46).

Scenario: Due to the impact of COVID-19, our institution has developed a policy to give students the option to receive a pass/fail grade for a term impacted by the COVID-19 qualifying emergency.

Answer: The school decides whether it will include pass/fall courses in the calculation of a student’s grade point average (GPA or qualitative component) when performing the satisfactory academic progress (SAP) evaluation. Typically, pass/fail courses are not factored into the qualitative component, but the courses do count toward the quantitative measure (pace of progression). This is not new and will continue after the qualifying emergency ends.

The May 15, 2020 Electronic Announcement broadens the school's authority to make changes to its existing SAP policy during the qualifying emergency:

"Students may be permitted to take some or all classes on a pass/fail basis. It is also permissible for an institution to administratively determine that all coursework in a term will be evaluated on a pass/fail basis. An institution may modify its policies restricting the number of courses students may take on a pass/fail basis to accommodate the national emergency due to the coronavirus. Where an institution has no existing policy allowing pass/fail grades, it may adopt one, even if only temporarily. Courses taken on a pass/fail basis count as attempts for SAP purposes. Generally, pass/fail grades are not factored into a student’s GPA. However, an institution may follow its own policy with respect to the effect of pass/fail grades on GPA."

This is consistent with the U.S. Department of Education's (ED's) previously existing guidance found in the 2019 FSA Training Conference session, Understanding Your Satisfactory Academic Progress Policy. How pass/fail grades impact students must be addressed in your SAP policy. For students with a mix of pass/fail courses and letter grades, all courses would count in the quantitative measure. However, courses for which the student received a pass/fail grade would be included in the qualitative component only if the school’s policy indicates if and how the pass/fail grades should be included. Likewise, our understanding is that those pass/fail grades would remain static in future SAP evaluations for those students; no GPA would be generated for those pass/fail courses.

The above guidance also applies to credit/no-credit classes.

End Date of this COVID-19 Waiver: According to guidance NASFAA has received from ED, "Because the COVID FAQ referenced was sub-regulatory and not formally part of the HEROES waivers or CARES Act, this specific guidance does not have an explicit end date and therefore, would actually continue to be applicable today. However, with that said, ED does not see this scenario as being very likely now since the threat and concerns related to COVID-19 have been greatly (if not completely) diminished."

CARES Act Waiver: That having been said, there is an alternative under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) for courses the student does not complete, including pass/fail courses the student does not complete. Per the CARES Act, "[I]n determining whether a student is maintaining satisfactory academic progress…an institution of higher education may, as a result of a qualifying emergency, exclude from the quantitative component of the calculation any attempted credits that were not completed by such student without requiring an appeal by such student.” This is an option your school may choose to utilize, though it is not a requirement. If you exercise this option and if you don't assign grades to pass/fail courses, this effectively means you would completely ignore pass/fail courses that the student does not complete in your SAP evaluations for the affected term(s). Whatever you decide, it must be documented in your SAP policy. See AskRegs Q&A, How Do We Treat COVID-19 Related Withdrawals In Our SAP Calculation?, for more on this alternative.

End Date of this CARES Act Waiver: This waiver ends at the end of the payment period that includes May 11, 2023.

Update Notes:

AskRegs Q&As represent NASFAA's understanding of regulatory and compliance issues. They are FOR INTERNAL USE ONLY. While NASFAA believes AskRegs Q&As are accurate and factual, they have not been reviewed or approved by the U.S. Department of Education (ED). If you should need written confirmation of AskRegs information for audit or program review purposes, please contact your ED School Participation Division. NASFAA shall not be liable for technical or editorial errors or omissions contained herein; nor for incidental or consequential damages resulting from the furnishing, performance, or use of this material.